After reviewing the best available scientific and commercial information, the Service finds that listing several giraffe species and subspecies is warranted. The Service proposes listing all three subspecies of the northern giraffe: West African, Kordofan and Nubian from west, central, and east Africa as endangered species under the Endangered Species Act of 1973, as amended. 

The Service also proposes listing the reticulated and Masai giraffes from East Africa as a threatened species with protective regulations under section 4(d) of the act.

The Service also finds that both subspecies of southern giraffe (Angolan and South African giraffe) are not warranted for listing under the ESA at this time. However, given their similarity of appearance to other giraffe species, the Service is proposing to treat the southern giraffe subspecies as threatened with a 4(d) rule.

The proposed rule, if finalized, will benefit giraffes by:

• Reducing illegal hunting and trade of giraffes by requiring permits for import into the U.S.
• Increasing U.S. and global awareness of the decline in giraffes, research efforts to address conservation needs, and funding for species conservation in its range countries.
• Providing limited financial assistance to develop and manage programs to conserve giraffes.

The primary purpose of the Endangered Species Act is the conservation of endangered and threatened species and the ecosystems upon which they depend. The ultimate goal of such conservation efforts is the recovery of these listed species so that they no longer need the protective measures of the ESA. Conservation measures provided to species listed as endangered or threatened species under the ESA include recognition as a listed species, planning and implementation of recovery actions, requirements for federal protection, and prohibitions against certain practices.

The ESA defines an endangered species as “any species which is in danger of extinction throughout all or a significant portion of its range.” Endangered species are automatically protected by prohibitions of several types of “take,” including harming, harassing, collecting, or killing, under section 9 of the ESA.

The ESA defines a threatened species as “any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” Threatened species receive protection through separate regulations issued under section 4(d) of the ESA. 

The Endangered Species Act requires the Service to list species as endangered or threatened regardless of which country the species lives in. Benefits to the species include prohibitions on certain activities including import, export, take, commercial activity, interstate commerce, and foreign commerce. By regulating activities, the United States ensures that people under the jurisdiction of the United States do not contribute to the further decline of listed species. Although the ESA’s prohibitions regarding listed species apply only to people subject to the jurisdiction of the United States, the ESA can generate conservation benefits such as increased awareness of listed species, research efforts to address conservation needs, or funding for in-situ conservation of the species in its range countries.

The protective regulations we are proposing for the reticulated giraffe, Masai giraffe, Angolan giraffe, and South African giraffe incorporate all prohibitions from ESA section 9(a)(1), which include imports into the U.S. and “take” as discussed earlier. The Service is also proposing that the import exemption for threatened wildlife listed in Appendix II of CITES (50 CFR 17.8; section 9(c)(2) of the act) would not apply. A threatened species import permit under 50 CFR 17.32 would be required for the importation of specimens of the species or subspecies, or a similarity of appearance import permit under 50 CFR 17.52 would be required for the importation of specimens of Angolan giraffe or South African giraffe, regardless of whether the trade is reported as for commercial or personal purposes to address the similarity of appearance issues. 

The Service is proposing that it may also authorize certain activities associated with conservation breeding under captive-bred wildlife registrations. The proposed 4(d) rule would apply to all live and dead reticulated giraffes, Masai giraffes, Angolan giraffes, and South African giraffes, including any part, product, egg, or offspring thereof, and support conservation management efforts for giraffes in the wild in Africa.

On April 19, 2017, the Service received a petition from the Center for Biological Diversity, Humane Society International, The Humane Society of the United States, the International Fund for Animal Welfare, and the Natural Resources Defense Council to list the giraffe (Giraffa camelopardalis) as threatened or endangered under the act.

On April 26, 2019, the Service published a 90-day finding that found that the petitioned action was warranted. 

A settlement agreement required the Service to deliver a 12-month finding/proposed rule to the Federal Register by Nov. 7, 2024.

The Service’s proposed endangered species status for the West African, Kordofan, and Nubian giraffe is based on the primary threats to the subspecies including changing habitat conditions caused by habitat loss, fragmentation, and degradation, and poaching. These threats are exacerbated by rapid human population growth as well as climate change climate change
Climate change includes both global warming driven by human-induced emissions of greenhouse gases and the resulting large-scale shifts in weather patterns. Though there have been previous periods of climatic change, since the mid-20th century humans have had an unprecedented impact on Earth's climate system and caused change on a global scale.

Learn more about climate change through drought and extreme rainfall. Changing habitat conditions reduce the availability of high-quality food, foraging habitat and protective cover. Other threats affect northern giraffes directly or compound these primary threats, such as low genetic diversity. Since 1985, the Service estimates that the population of northern giraffes has declined by 77%; the current population is estimated to be less than 6,000 individuals – approximately 600 West African; 2,297 Kordofan; and 3,022 Nubian giraffes. 

The Service’s proposed threatened species status for the reticulated and Masai giraffes is based on threats including habitat loss, fragmentation, and degradation because of the conversion of natural habitats and vegetation to croplands and urbanization, and poaching for consumption, personal use, or trade, which are exacerbated by rapid human population growth and the effects from climate change climate change
Climate change includes both global warming driven by human-induced emissions of greenhouse gases and the resulting large-scale shifts in weather patterns. Though there have been previous periods of climatic change, since the mid-20th century humans have had an unprecedented impact on Earth's climate system and caused change on a global scale.

Learn more about climate change .

The Service has determined that both subspecies of southern giraffe (Angolan giraffe and South African giraffe) have sufficiently large, connected populations to sustain viability and that while both subspecies continue to face threats within their range, these threats have not resulted in population declines for either subspecies. Rather, these subspecies are currently experiencing population increases due to management by range countries to sustain ecotourism and trophy‐hunting activities, which in turn may be managed to produce revenues that are used by range countries and local communities for giraffe conservation activities such as anti-poaching, reintroduction, and habitat preservation and restoration to benefit and address the threats of giraffe.

Giraffes are protected by international agreements that include regulations on trade, conservation efforts, and raising awareness about their protection in Africa. Key agreements include the Convention on International Trade in Endangered Species of Wild Fauna and Flora, the Convention on the Conservation of Migratory Species of Wild Animals, and the African Union, all of which require member countries to implement measures to reduce illegal trade in giraffes. 

The primary threats to all giraffes include human population growth; habitat loss, fragmentation, and degradation due to development for urbanization and agriculture; poaching; and the impacts of drought from climate change climate change
Climate change includes both global warming driven by human-induced emissions of greenhouse gases and the resulting large-scale shifts in weather patterns. Though there have been previous periods of climatic change, since the mid-20th century humans have had an unprecedented impact on Earth's climate system and caused change on a global scale.

Learn more about climate change , which influence human-wildlife conflicts.

Historically, giraffes have been sought for their hair, tails, and medicinal uses, but they have been increasingly poached for bushmeat. Giraffe parts frequently appear in international commercial trade, although uncertainties often exist regarding the country of origin, subspecies (or species), and the specimens' legality.

The populations for the three subspecies of northern giraffe have declined approximately 77% since 1985, from 25,653 to 5,919 individuals (approximately 600 West African, 2,297 Kordofan, and 3,022 Nubian), and it has been extirpated from numerous countries in West Africa.

All 600 West African giraffes live in the Giraffe Zone in the arid Sahelian scrubland east of the Niger capital, Niamey, and part of the transition zone of Niger’s West National Park Biosphere Reserve. The Giraffe Zone is an unprotected and unfenced area where giraffes move freely and migrate based on seasonal availability of forage, giraffe carrying capacity in the core area, and increasing pressure from a growing human population. Giraffes share their living space with local villagers and livestock, and their movements are synchronized with human activities based on habitat and forage availability. Within the Giraffe Zone, West African giraffes are not formally protected, and poaching currently appears to be rare.

Kordofan giraffe populations have declined from 64% to 69% since the 1950s, when they numbered 6,370 to 7,360 individuals. The population is expected to continue declining at a rate of 1.5% to 7% per year. The majority of the population (80%) is found in national parks in Cameroon and Chad.

Nubian giraffe populations have declined 86% from the 1960s to the1980s population of 21,907. Populations are expected to decline by approximately 5% annually. The majority of Nubian giraffes (approximately 60%) occur in one population at Murchison Falls National Park, Uganda.

The population of reticulated giraffes has declined since 1985, when there were more than 30,000 individuals. By the early 2000s, the population declined to 15,985 individuals, with 99% of the population in Kenya, and only a small population in southern Ethiopia. This current population represents approximately 33% to 44% of the historical population size.

Before the 1980s, the population of Masai giraffes was approximately 68,000 giraffes, but since then the population has been declining by approximately 1% to 3.3% per year for a total decline of 32% to 34%. The most recent population estimate for the species is 45,402 individuals (66% to 68% of its historical abundance) and declining, with most of the population in southern Kenya and northern Tanzania.

Whenever a species is not endangered or threatened but closely resembles an endangered or threatened species, that species may be treated as either endangered or threatened under section 4(e) of the ESA for similarity of appearance.

Under section 4(e), the Service determines similarity of appearance based on three factors:(a) the species so closely resembles in appearance, at the point in question, a listed threatened or endangered species that enforcement personnel would have substantial difficulty in attempting to differentiate between the listed and unlisted species; (b) the effect of this substantial difficulty is an additional threat to an endangered or threatened species; and (c) such treatment of an unlisted species will substantially facilitate the enforcement and further the policy of this ESA.
 

Yes. It is nearly impossible for law enforcement, using either morphology or genetics, to differentiate giraffe species or subspecies. Morphologically, while some subspecies have been described to have distinct external morphological characteristics when provided a complete specimen, there is considerable variation and overlap in giraffe morphology, particularly in the parts and pieces that are commonly in the trade (e.g., small patches of skin, carved bones), which would are not identifiable beyond species.

Similarly, Service law enforcement can only identify one species of giraffes, following both the current Convention on International Trade in Endangered Species of Wild Fauna and Flora and the International Union for Conservation of Nature taxonomies that consider giraffes one species with nine subspecies. Despite some recent taxonomic revisions in giraffes, the genetic datasets for this work are either currently not available or verified to allow Service law enforcement to distinguish giraffes beyond the species level for enforcement purposes.

Yes. The listing of the Angolan giraffe and South African giraffe due to similarity of appearance will facilitate federal, state, local, and foreign law enforcement agents’ efforts to restrict unauthorized taking and trade in the West African giraffe, Kordofan giraffe, Nubian giraffe, reticulated giraffe, and Masai giraffe. We find that listing the Angolan giraffe and South African giraffe due to the similarity of appearance under section 4(e) of the ESA and providing applicable prohibitions and exceptions under section 4(d) of the act will substantially facilitate the enforcement and further the policy of the act for the West African giraffe, Kordofan giraffe, Nubian giraffe, reticulated giraffe, and Masai giraffe.

If the Angolan giraffe and South African giraffe were not listed, importers and exporters could inadvertently or purposefully misrepresent the West African giraffe, Kordofan giraffe, Nubian giraffe, reticulated giraffe, and Masai giraffe (e.g., specimens, parts) as the unlisted entity, creating a loophole in enforcing the act’s protections for listed species of giraffe.
 

If this rule is finalized as it is proposed, it would prohibit the import of a sport-hunted trophy of an Angolan giraffe or South African giraffe into the United States unless that import has been authorized or permitted. The Service would require a permit application providing adequate information to document that the trophy specimen is an Angolan giraffe or  South African giraffe. This requirement would ensure against imports or exports of West African giraffe, Kordofan giraffe, or Nubian giraffe without an endangered species permit, and against reticulated giraffe and Masai giraffe without a threatened species permit. This requirement would thus help conserve all five of these species.

Giraffes are protected under the Convention on International Trade in Endangered Species of Wild Fauna and Flora primarily because their populations are vulnerable to threats from habitat loss, illegal hunting, and the international trade of giraffe parts. Trade is not the primary cause of the decline of wild giraffe populations; however, trade may have an additive effect when combined with the main causes of habitat loss and poaching.